By Payam Pourkhomami, President & CEO of OSIbeyond
On Nov. 10, 2025, DFARS 252.204-7021 officially started requiring defense contractors to maintain CMMC certification at levels specified in their contracts. What many contractors don’t realize is that their eligibility for award is determined earlier in the process by a different provision, or DFARS 252.204-7025.
In this article, we explain everything defense contractors need to know about DFARS 252.204-7025, including what it requires, how it fits into the broader cybersecurity framework and what you should do when you encounter it in a solicitation.
What DFARS 252.204-7025 Actually Does
DFARS 252.204-7025 is a short solicitation provision titled “Notice of Cybersecurity Maturity Model Certification Level Requirements.” It appears in the solicitation documents (before you’re awarded a contract) to notify potential offerors that they’ll need to meet specific CMMC requirements to be eligible for award.
The purpose of DFARS 252.204-7025 is straightforward: prevent contractors from wasting time preparing proposals for contracts they can’t legally win.
The provision starts by telling you exactly which CMMC level the contract requires. The contracting officer fills in one of four options:
- CMMC Level 1 (Self): For contracts involving only Federal Contract Information, or FCI, where contractors can self-assess against 17 basic safeguarding requirements
- CMMC Level 2 (Self): For certain limited contracts involving Controlled Unclassified Information, or CUI, where self-assessment against all 110 NIST SP 800-171 controls is permitted
- CMMC Level 2 (C3PAO): For most contracts involving CUI, where third-party assessment by a CMMC third-party assessment organization is mandatory
- CMMC Level 3 (DIBCAC): For contracts involving the most sensitive CUI, where assessment by the Defense Industrial Base Cybersecurity Assessment Center is required
The provision then makes clear what “eligible for award” means. You will not be eligible for award unless you have two specific items for each relevant information system. First, you need a current CMMC status entered in the Supplier Performance Risk System, or SPRS, at the required level. Second, you need a current affirmation of continuous compliance with the security requirements in SPRS. Both must be current at the time of award.
“Current” has a specific meaning in the context of DFARS 252.204-7025, as your CMMC status is valid for three years from the date of assessment and your affirmation of compliance must be updated annually by a senior company official. If either one lapses, you’re not eligible.
The provision also addresses what happens if you have a conditional CMMC status rather than a final one. Specifically, if you are awarded a contract with a conditional status (meaning a third-party assessor found certain deficiencies that you’ve documented in a plan of action and milestones, or POA&M), you must close out that POA&M within 180 days to achieve final status. The provision references 32 CFR 170.21 for the rules governing which deficiencies qualify for conditional status.
Finally, the provision requires you to provide CMMC Unique Identifiers, or UIDs, in your proposal. A CMMC UID is a 10-character alphanumeric code assigned in SPRS to each assessed information system. You must list every CMMC UID for each system that will handle FCI or CUI during contract performance and update the list whenever new UIDs are generated (such as bringing a new system into scope or completing a reassessment).
How DFARS 252.204-7025 Fits in the Cybersecurity Framework
To understand where DFARS 252.204-7025 fits into the broader DoD cybersecurity ecosystem, it helps to see it alongside related contract clauses.
Here’s how the main DFARS cybersecurity requirements pair together:
Provision, or Gives Notice | Contract Clause, or Creates Obligation | What It Covers |
| DFARS 252.204-7008 | DFARS 252.204-7012 | Safeguarding covered defense information and cyber incident reporting |
| DFARS 252.204-7019 | DFARS 252.204-7020 | NIST SP 800-171 DoD Assessment Requirements |
| DFARS 252.204-7025 | DFARS 252.204-7021 | CMMC certification requirements |
When you see 7025 in a solicitation, you know that 7021 will be in the resulting contract. When you see 7008, you know 7012 obligations are coming. This advance notice gives you time to assess whether you can meet the requirements before investing resources in a proposal.
The numbering system itself is arbitrary, but the function is consistent. Provisions appear during the solicitation phase to alert offerors about upcoming obligations. Clauses appear in the contract to enforce those obligations once awarded.
For DFARS 252.204-7025 specifically, it serves as your earliest formal warning that CMMC certification will be required. The provision doesn’t create new technical requirements beyond what CMMC already mandates. It simply makes the requirement explicit and verifiable at the solicitation stage rather than leaving it ambiguous until contract award.
What to Do When You See DFARS 252.204-7025 in a Solicitation
Encountering DFARS 252.204-7025 in a solicitation should trigger an evaluation process to determine your eligibility for award and the actions needed before proposal submission.
- Verify your current CMMC status matches the required level. Check both the certification level and the expiration date. If your certification expires before the expected award date, you need to plan for reassessment or renewal. If you lack certification at the required level, you must complete the full compliance and assessment process before you can compete, which typically takes six to 12 months for Level 2 certification.
- Confirm your annual affirmation is current. Even with valid certification, you need a current affirmation of continuous compliance in SPRS. Check the date of your most recent affirmation. If it’s approaching the one-year mark or has already lapsed, designate a senior company official to submit an updated affirmation immediately.
- Identify all information systems that will handle covered information during performance. Map your technical approach to specific information systems and determine which will process, store or transmit FCI or CUI under the contract. Each system must have CMMC certification at the appropriate level and a corresponding CMMC UID in SPRS.
- Gather all CMMC UIDs for inclusion in your proposal. Compile the 10-character alphanumeric CMMC UIDs for each relevant information system from SPRS. Include this information in your proposal exactly as required by the solicitation instructions. Missing or incorrect UIDs can make your proposal non-responsive.
- Plan for supply chain compliance if you’re a prime contractor. Identify which subcontractors will handle covered information and verify their CMMC certification status. Flow down the appropriate CMMC requirements in your subcontract agreements and remember that your certification doesn’t cover your subcontractors’ systems. They need their own certifications for their portions of work.
For contractors who discover they’re not currently eligible for award, the path forward involves partnering with experienced CMMC consultants or certified Managed Service Providers, or MSPs, who can accelerate the compliance journey. The investment in expert guidance pays for itself through faster time-to-certification and higher probability of passing assessment on the first attempt.
As part of our comprehensive CMMC compliance solutions, OSIbeyond has developed two fixed-price CMMC solutions (PDF) specifically designed for defense contractors at different stages of the compliance journey:
- Our GCC Enclave Deployment solution is intended for organizations that have existing IT infrastructure but need to create a secure, compliant environment specifically for handling CUI.
- Our GCC Full Migration solution is aimed at organizations that want to move their entire IT environment to FedRAMP-authorized government cloud infrastructure.
Both solutions include the development of System Security Plans, implementation of required security controls, configuration of audit logging and monitoring systems and preparation for C3PAO assessment.
Conclusion
DFARS 252.204-7025 may be just a few paragraphs long, but it serves as a critical checkpoint in the DoD contracting process because it filters out non-compliant bids early, saving both contractors and the government from wasted effort on proposals that can’t result in awards.
As more solicitations incorporate DFARS 252.204-7025 and the phased implementation of CMMC continues through 2028, contractors who delay compliance work will find themselves increasingly locked out of opportunities. The assessment ecosystem already shows signs of capacity constraints, with some C3PAOs booked many months in advance. Contractors who wait until they see this provision in a solicitation have likely already missed their window to compete effectively.
